ML20126F435

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Responds to & Addl Info Provided Re Transfer of Certificates of Compliance.Agrees That Fabrication Need Not Be Included in Certificate Holders QA Program Provided Fabrication Activities Not Conducted
ML20126F435
Person / Time
Site: 07100397
Issue date: 10/20/1992
From: Macdonald C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Vogt J
TELEDYNE ENERGY SYSTEMS
Shared Package
ML20126F421 List:
References
NUDOCS 9212300307
Download: ML20126F435 (1)


Text

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OCT 2 01992 (~~'\

O- U 4

Teledyne Energy Systems ATIN: Mr. John F. Vogt Program Manager 110 W. Timonium Road Timonium, MD 21093

Dear Mr. Vogt:

I am responding to your letter of May 22, 1992, and the additional information provided concerning the transfer of certificates of compliance. '

As stated in 10 CFR Part 171;_ quality _.ailurante_ program _apprmalLaye divided

--4*ttr-t'wo major groups: (1) those activities including design, fabrication and-use of packaging, and thost activities for use only of packaging.

'TITGTher, the3e prUgrim(2)s, when properly implemented within their respective scope of activities, meet the requirements of 10 CFR $71.101. The former program approval is held by the certificate holder (usually a packaging owner) and includes the maintenance of all quality-related documents. The certificate holder may also provide certifications to other licensee-users for activities conducted which were not within the licensee-user'- %ediate control. In any event, it remains the responsibility of each licensee-user that its transportation activities meet the requirements of 10 CFR Part 71.

In view of the above, I would agree that fabrication need not be included in a e

,cerlilitate _ holder's quaTity aisutaate_pIngr_am_provfded f abricati6TETCUVitre~s?

are not conducted, or are complele_d_.anLthe_ Quality records are maintained for_

-eath pacjka 13)s, However, each certificate holder's quality assurance program _

~ must address design,. This is necessary in order to request renewals or modMTcations that may be required and for cases where a certificats of compliance is transferred. . Transferring a certificate requires that the new Jertificate holder accept _the_ stat.ements and_represeitatTUn> for which the '

cerriTicatowas~Jssued. Under this arrangement all the provisions for use of

'an. existing package under the general license provisions of 10 CFR Part 71 may be satisfied.

I trust that this information will be helpful.

Sincerely, Original Signed By Charles E. MacDonald, Chief Transportation Branch Division of Safeguards and Transportation, NMSS 9212300307 921204 7 PDR ADOCK 0710 C